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CRA stated: One of the conditions for making a section 167 election is that if the supplier is a registrant, the recipient must be a registrant … [which] is a question of fact … There is no provision deeming a predecessor (in this case, Newco) to acquire the characteristics of its successor Amalco. ...

The circumstances of these supplies can be differentiated from the supply of [the Assessment] in that the purpose for these supplies is the examination by the physician or the review of a report by the physician. […] [The Assessment] supplied by [ACo], […] is a multi-disciplinary assessment conducted by a number of different service providers including…. ...

Therefore … subparagraph 173(1)(d)(i) would not apply …. ...

. … In this case, the CRA would treat 90% of the claim under Category 1 and the other 10% would likely fall under Category 2. ... CRA responded: VDP applicants are required to submit information for the 4 calendar years before the date the application is filed for applications processed under Category 1 or Category 2 … [and] would only be expected to include information and payment of the estimated tax owing for 4 calendar years before the date the application is filed even if the error was made for more than the 4 calendar years prior to the date of filing. … If an application that was believed to fall under Category 1 (GST/HST wash transaction) or Category 2 (General program) is reclassified, in part or in whole to Category 3 (Limited program) by the CRA, the applicant will be required … to pay the additional taxes …. ...

11 April 2016 CRA Press Release “Government of Canada cracks down on tax evasion”-- summary under Subsection 152(1) Summary Under Tax Topics- Income Tax Act- Section 152- Subsection 152(1) expansion of audit review of aggressive tax avoidance and evasion/embedded lawyers [T]he Government of Canada will invest over $444 million to enhance the Canada Revenue Agency’s (CRA) ability to detect, audit, and prosecute tax evasion – both at home and abroad. …This will result in a twelve-fold increase in the number of tax schemes examined by the CRA…[and] will increase the number of examinations focused on high-risk taxpayers – from 600 per year to 3000 per year – and will bring in $432 million in new tax revenue. ...

. … For example, in the case of an annual bonus paid by an eligible employer to an eligible employee, it would generally be reasonable to consider that the annual bonus was earned throughout the fiscal period to which it relates. ... It would also be reasonable, for purposes of computing baseline remuneration, to calculate the average weekly eligible remuneration by dividing the bonus amount by the number of weeks included in the period to which it relates …. [Q.17-6] Apportionment of commissions To determine whether a commission payment is in respect of a specific week, it is necessary to review the complete set of facts pertaining to a particular situation, including the employment contract … [and] practices specific to a particular industry …. ...

Examples of acceptable variations – COLA Many RPPs provide cost-of-living adjustments that are based on the full Consumer Price Index (CPI). ... Commutation of PV of RPP benefits to acquire life annuity [T]he terms of the plan … might allow a member to use their commuted value to buy a life annuity from a licensed annuity provider. … A commuted value cannot be used to purchase an annuity that is materially different from the RPP, based on the plan as registered. ... Any excess must be distributed on a taxable basis If the commuted value is greater than the cost to buy an annuity that replicates the RPP benefits, the excess commuted value cannot be used to provide higher annuity payments under the annuity contract. … Under [Reg.] 8502(d)(ix) … the portion of the commuted value that is in excess of the annuity acquisition cost can be paid in cash to the individual and must be included in income for tax purposes. … Use of excess assets e.g., in IPP to purchase further benefits If there are excess assets in the RPP, to the extent that lifetime retirement benefits and ancillary benefits are not at the maximum allowable under the Act, benefits can be enhanced through a plan amendment before being settled by an annuity purchase. ...

These and related changes are reflected in the updated CRA Webpage on the “ Pertinent loans or indebtedness (PLOI) ”. ...

Where an election is made, if an amount becomes receivable after 2016 as proceeds of disposition upon the satisfaction of a condition that was part of the agreement under which the disposition was made and the amount would otherwise result in a capital gain for the taxpayer, the amount would under the proposed amendment instead be taxed as it would have been under the ECP regime, with one-half of the gain included in computing the taxpayer's income from a business for a taxation year and the other half … in the taxpayer's capital dividend account. … The taxpayer would need to file this election no later than the filing-due date for the taxpayer's first taxation year that ends after September 30, 2019. ...

The payer can ask for relief on penalties and interest by writing to their tax services office or by submitting a completed Form RC4288, Request for Taxpayer Relief – Cancel or Waive Penalties or Interest. ... Collecting the appropriate forms or equivalent information will help show the payer tried to apply the correct tax rate. ¶ 21. ... (CDS) on securities registered in the name of Cede & Co. Tax on these payments is withheld by CDS based on information it receives from the Depository Trust Company (DTC) and collected by DTC participants. ...